#15

08/21/14

Developing an Organic Control Point Program

Using the HACCP Model
In their Organic System Plan (OSP), operations must describe the management practices and physical barriers they use to prevent
contamination of their organic products and the commingling (mixing) of organic and nonorganic products. Organic product processors must identify the points in their process where organic integrity may be lost, and then establish measures to control these
points. This plan is called an Organic Control Point (OCP) Program.
Hazard Analysis and Critical Control Point (HACCP) is a systematic approach that identifies specific hazards that negatively affect
the safety of food, and specifies measures for their control. The HACCP approach can be used as a model for developing an
OCP Program. The HACCP model serves as an effective structure for managing these risks.
NOP Citation: 205.272

7 steps to develop a HACCP-based OCP Program:

1. HAZARD ANALYSIS

Proper monitoring should address:

Prepare a flow chart of every step in the process. Identify and

list the hazards that threaten organic integrity together with
their causes and sources. Determine which hazards are significant.

2. DETERMINE THE OCPs (Organic Control Points)

OCPs are points or procedures in the organic system where
organic integrity may be lost due to the commingling with
non-organic product or contamination with prohibited substances.
Examples:

Receiving of organic and non-organic ingredients

Sanitation and pest control

Use of the same equipment for organic and nonorganic products

Storage of organic and non-organic materials in the

same area

Packaging and labeling

Transportation of organic and non-organic materials

in the same load
3. ESTABLISH CRITICAL LIMITS
Critical limits are established to ensure that each OCP is under control. The critical limit is what separates acceptability
from unacceptability.
4. MONITORING SYSTEM
Establish a system to monitor the control of each OCP and
ensure it is working. Examples include scheduled testing or
observations. Keep accurate records of monitoring results.

How the monitoring is to be carried out

When the monitoring is to be carried out
Who is responsible for carrying out the monitoring
The record to be taken

5. CORRECTIVE ACTION
Establish corrective action to be taken if a particular OCP is
not under control or shows signs of instability. For example,
in the case of a contaminated organic product, shipment may
be stopped until the issue is resolved.
6. VERIFICATION
Establish procedures for verification to confirm that the
system is working effectively. This should include validation
and review activities.
7. DOCUMENTATION
Establish documentation concerning all procedures and
records appropriate to these principles and their application.
Effective recordkeeping is key in documenting each step of
the process. Records must be available for the onsite inspection or added to the Organic System Plan (OSP) for review.

See reverse side for a sample

HACCP-based OCP Program.

A Sample HACCP-based Organic Control Point (OCP) Program:

Steps 1-2

Process Step

Organic Hazard
introduced,
controlled or
enhanced
at this step

Labeling

Improper labeling of
non-organic product
as organic product

Is the
potential for
Organic
Hazard
significant?

Justification for
decision
regarding
hazard level

Control measure
taken to
prevent organic
hazard

Is this step an
Organic Control
Point?
If so, how is that OCP
identified?

Yes

The wrong label

stock could be
used when
labeling

Cross-verification of
proper labels when
labeling
organic

Yes OCP 7

Steps 3-7
Organic
Control
Point
(OCP)

Critical
Limit

OCP 7
Labeling

Zero
nonorganic
product
labeled as
organic

Monitoring
What

Finished
Product

How

Labeling
report and
computer
verification
of inventory

Frequency

Prior to
labeling
each and
every order

Responsibility

Warehouse
operator
and
supervisor

Corrective Action

Verification

Record
Keeping

In the event that

non-organic product is
labeled as organic the
product will be isolated,
the label removed, and
re-labeled under the
guidance of quality
assurance

Crossverification
of label and
stock

Labeling
report

Helpful Resources:
http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5090759